WBONO0001503
WBON0001503
From: Gideon Cohen
1 Beezer
Amy Prime {
, Owain Draper
Ce: Anthony Grabiner {_
Subject: Compiling spreadsheet/ feeding into WS
Date: Mon, 18 Mar 2019 10:50:41 +0000
Importance: Normal
Attachments: Notes_for_recusal_application.docx
>, Stephanie Wood
All,
Following discussion with AGQC, I have worked up the attached, which seeks to synthesize our arguments
on the key bias points.
Any comments/ suggestions gratefully received.
A few important things to note:
- Particularly helpful if people can play devil's advocate and come up with arguments for why some of these
findings should have been included. For a number of them I have drawn a complete blank.
- This analysis should also plug into the witness statement being prepared by WBD in support of the
application.
- Tam conscious that I am not close to the detail of the Horizon trial. Would be good if those who are
involved could scrutinize the parts dealing with that overlap especially carefully.
- As I have commented before, this is a 'target-rich' environment. We have to choose the best egs.
Accordingly, I have ditched the couple of glancing references to matters relevant to loss and damage.
- This does not include the 'vitriol' points. I note that some of these are toned down in the final version of the
Judgment. We will have to decide precisely what role we want these points to play in the application.
Best
Gideon
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR
www.oeclaw.co.uk
The contents of this email are CONFIDENTIAL and may be PRIVILEGED. If you are not the intended
recipient, please telephone and delete this email.
WBD_001373.000001
WBONO0001503
WBON0001503
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WBD_001373.000002